
Digital Product Passport for luxury goods
The Digital Product Passport for luxury goods follows the rules for apparel and gold in the ESPR and the minerals rules. It has no act of its own.
Where Transpareo supports you
Today no act requires a passport for watches, jewellery or leather goods. Apparel needs one once the act for textiles applies. Transpareo is the DPP platform on which you give every object a signed record, required or not. The cards lead to the sections further down.
In this industry the value lies in the individual piece. Transpareo keeps item passports with serial numbers and creates the QR code for the guarantee card, label or engraving.
Buyers and resellers want to see that a record comes from you. Every publication is signed, and anyone verifies it with the Transpareo Time Machine.
Repair and refurbishment are part of a piece’s history. In Transpareo each of these events adds a signed version, and earlier versions stay retrievable.
Gold, stones and leather raise questions of origin. Origin and evidence sit on every component, and with Transpareo Upstream suppliers enter their details themselves.
Care instructions and service intervals bring the owner back to you. The passport page shows care, the workshop’s story and your contact, with your branding.
Customer data goes into the passport only with consent. In Transpareo the owner-facing part stays behind logged access, while the service history can be public.
Large companies may no longer destroy unsold apparel and footwear, and they disclose what they discard. In Transpareo you keep the product data for that per model and item.
A watch changes hands over decades. In Transpareo every passport keeps a permanent address, and once registered, Transpareo Vault archives it for ten years.
Provenance and care texts need the language of every market. Transpareo translates them into 40 languages, and you check them before publication.
What applies to luxury goods makers
The Digital Product Passport for luxury goods has no act of its own. Several EU rules reach this industry today all the same. Transpareo is the DPP software maisons use to give their objects a signed record.
Where the law stands
There is no passport act for watches, jewellery or leather goods. None of them appears as a product group in the Commission’s first ecodesign working plan of 16 April 2025. Apparel does, with a delegated act in the indicative year 2027.
The Commission judged footwear less impactful than the priority groups. It gets a study, due to conclude at the end of 2027. So there is no date on which luxury becomes regulated. A mid-term review of the working plan is planned for 2028 and can add product groups.
What already binds you
Since 1 January 2021 Union importers of tin, tantalum, tungsten and gold have owed a documented due diligence chain. That applies above the volume thresholds of the Conflict Minerals Regulation. The chain reaches every watch case and every gold setting.
Since 19 July 2026 large companies may no longer destroy unsold apparel, clothing accessories and footwear. From 19 July 2030 the same applies to medium-sized ones. Fineness marks for precious metals remain national. A piece sold in four markets still meets four hallmarking regimes.
For leather the picture has changed. Since 18 September 2026 cattle leather no longer falls under the Deforestation Regulation.
What drives passports here
In this industry counterfeiting and resale drive passports forward.
A counterfeit is cheap to make and expensive to disprove. A pre-owned object without a verifiable history loses much of its value at the second sale.
Both problems have the same shape: a claim about an object that nobody can check. A signed record per item fixes that. If an act comes later, it will most likely ask for the same data.
What this page covers
This page is your reference work on the Digital Product Passport for luxury goods. It shows the fixed and the expected dates, the roles with their duties and the data of an item passport. Then come the official sources and the questions this industry asks us most often. A term underlined with dots shows the wording of the provision.
What a passport brings you now
Authentication becomes a scan. A buyer, a boutique or a resale platform checks the signature in the browser. So they see that the object’s record came from you.
A signed record per item turns three costs into three advantages.
Resale keeps its value, because repair and refurbishment travel with the object as versions of one passport. And the object keeps talking to its owner after the sale. Care, the workshop’s story and your contact appear in the owner’s language, on a page with your branding.
The three biggest hurdles in practice
- Item level from day one: a model passport is cheap and carries little weight in this industry. Serial number, manufacturing date, service history and authentication live on the individual object. If the data model starts at the reference, it has to be rebuilt. In Transpareo the passport starts at item level.
- The chain is longer than the contract: origin data for gold, stones and hides sits two or three tiers upstream. The suppliers there have no contract with you. That data arrives through purchasing terms, and purchasing terms take months. A supplier request in Transpareo also reaches your suppliers’ own suppliers.
- The object outlives everything around it: a watch is resold decades after the boutique that sold it closed. A broken link then does more harm than no passport at all. The buyer reads it as a warning sign. In Transpareo every passport keeps its permanent address.
More on this: signatures and certificates in the DPP and from compliance document to marketing tool.
Regulatory timeline for luxury goods
The key dates of the rules that apply to luxury goods or are still to come, in order. Dates that hang on acts not yet adopted are marked as such.
- 1 January 2021Conflict-minerals due diligence applies
Union importers of tin, tantalum, tungsten and gold above the volume thresholds run a management system and assess risks. They have the chain audited by a third party and report publicly. Regulation (EU) 2017/821 requires it. Gold is the metal that reaches watch cases and jewellery.
- 16 April 2025The ESPR working plan names its priorities
The Commission adopts the first ecodesign and energy labelling working plan. Textiles, with the focus on apparel, is the first non-energy product group. Furniture, tyres, mattresses, iron and steel and aluminium follow. Footwear is not among them.
- 19 July 2026Destroying unsold apparel and footwear becomes unlawful
Large companies may no longer destroy unsold consumer apparel, clothing accessories and footwear. Medium-sized companies follow on 19 July 2030, and micro and small companies are exempt. The duty to disclose what was discarded every year comes with it.
- 20 July 2026EU DPP register goes live
The central registry of the ESPR starts operating. Implementing Regulation (EU) 2026/1778 governs it, with a test environment. Every future passport in this industry is registered there, whichever act eventually mandates it.
- 18 September 2026Cattle leather leaves the Deforestation Regulation
Delegated Regulation (EU) 2026/2102 enters into force. It deletes raw, tanned and further-prepared cattle hides and leather from the list of the Deforestation Regulation. Leather no longer needs a due diligence statement.
- Expected 2027Delegated act on textiles and apparel
The working plan gives 2027 as the indicative year for the textiles act, and the Commission plans it for the fourth quarter. The passport for apparel and the requirements behind it arrive with that act. It has not been adopted, so no date binds anyone yet.
- Expected end of 2027The footwear study concludes
The Commission judged footwear to have lower impacts than the priority groups. It commissioned a study for it, due to conclude by the end of 2027. So requirements for shoes can hardly arrive before 2030.
- 19 July 2030The destruction ban reaches medium-sized companies
What has applied to large companies since 2026 applies to medium-sized ones from this day. The disclosure duty follows the same step.
- Not yet fixedWatches, jewellery and leather goods
None of these is a product group in the first working plan, and none has a passport act of its own. A mid-term review of the working plan is planned for 2028 and can add product groups. Until then, any passport in these categories is a business decision.
Who is affected?
Duties for luxury goods: what falls on each economic operator on the way to the market.
Whoever makes the object, or has it made under their own name, holds the record. That covers materials, origin, the workshop and the conformity claims. Where an act under the Ecodesign Regulation arrives, this party creates the passport and keeps it accurate and up to date.
Whoever brings goods into the EU places them on the market and answers for the information that comes with them. For gold, tin, tantalum and tungsten above the volume thresholds the importer also owes the due diligence record. The importer settles that data with its suppliers in the purchasing contract.
Checks that what it sells carries the markings, the accompanying information and, where required, a reachable passport. Holds no passport data of its own. This is where a missing passport turns into a lost sale. The new Union Customs Code arrives on 21 September 2027. For distance sales to consumers from outside the EU, the seller or the marketplace is then the importer, depending on the arrangement. That importer makes sure the goods meet the product rules customs apply.
The secondary market is where a passport earns most of its value. It is also where its chain breaks most often. A repair, a re-certification or a resale should extend the existing record. Then the object’s history stays one chain. Where a new passport is created after all, it is linked to the original.
What belongs in a DPP for luxury goods?
Data fields of a voluntary passport for luxury goods, including data current EU law already asks for.
This covers the serial or item identifier, model, reference, and the date and place of manufacture. Everything else on this list hangs on this field. A model-level passport cannot provide it.
This covers metals, stones, leather and textile fibres with their origin. For tin, tantalum, tungsten and gold, the importer's due diligence record comes on top. Fineness marks for precious metals still follow the national hallmarking rules of each market.
This covers manufacturing technique, the workshop, care instructions, service intervals, spare parts and where to have work done. These are the fields that make an owner open the passport a second time, years after the purchase.
This covers the repair and service history and the authentication checks on resale. Large companies in apparel and footwear also need data for the disclosure of the unsold goods they discard.
Checklist for luxury goods
No act fixes which data points a product passport for luxury goods has to carry, and none is planned for the industry as such. That is why this page has no checklist. What applies today is set out in the data fields above and the official documents below.
Transpareo for luxury goods
Transpareo is the DPP software for maisons and makers of luxury goods. It keeps passports per item, with the fields this industry needs: identity, materials and origin, craft and care, service and repair. With a GTIN the identifier becomes a GS1 Digital Link, and without one Transpareo issues its own. Transpareo also creates the QR code for the guarantee card, the label or the engraving.
Data comes in through the web interface, by Excel import or through the API. Suppliers enter origin details themselves through a request. Every field has its own reading tier. Materials and care can be public, while ownership records stay behind logged access.
Every publication is a signed version, and earlier versions stay retrievable. Years later a resale platform verifies with the Transpareo Time Machine that the record came from you. Care and provenance texts appear in 40 languages, checked by you. Every passport keeps its permanent address.
Frequently asked questions about the DPP for luxury goods
Is there a DPP obligation for luxury goods today?
No. There is no passport act for watches, jewellery or leather goods. None of them is in the first working plan under the Ecodesign Regulation. Apparel comes closest to a fixed direction. The textiles act carries an indicative year of 2027 in the working plan, and the passport requirements arrive with it. Other rules bind you today. They include the due diligence duties for gold and other metals. Since 19 July 2026 the ban on destroying unsold apparel and footwear applies as well. A passport pays off even without an act. It makes authenticity verifiable in a scan and keeps resale value through its history. And it keeps the owner in touch with you.
Which of my product lines are already in scope?
Ready-to-wear falls under the textiles work, so an act will reach it. Footwear is not in it. The Commission judged its impacts lower than the priority groups. It commissioned a study, due to conclude at the end of 2027. Handbags, watches and jewellery are in no product group at all. If you sell across all four lines, you will switch the categories on at different times. So build the passport structure once for every line. In Transpareo you keep all lines on one platform.
Does this apply to importers too?
For the minerals rules, the importer is the addressee. The duty falls on the Union importer whose annual volumes exceed the thresholds. A future passport act will follow the familiar pattern. Responsible is whoever places the product on the EU market. In both cases the work lies in the contract, since the data sits upstream. Settle the data clauses in the purchasing contract before you need them. With a supplier request in Transpareo your suppliers then enter the details themselves.
Do I need a GTIN?
No. A passport needs a persistent unique product identifier. The regulation prescribes no particular numbering scheme. Many maisons already carry an internal reference and a serial number, and those are enough. If you have GTINs, Transpareo turns them into a GS1 Digital Link that retail systems resolve as well. Without one, Transpareo issues a unique identifier of its own. Either way the QR code leads to the passport, engraved, printed or on the guarantee card.
Model passports or one per item?
In this industry, per item. Which level applies is for the act of each product group to set. A model passport tells a buyer what a reference is. Only an item passport carries this object’s serial number, its manufacturing date and its service history. Transpareo keeps passports per model, batch or item. Item level costs you nothing structurally. It is the same template with serial numbers underneath.
Does a passport actually stop counterfeits?
Not on its own. A counterfeiter can print your QR code onto a copy. A passport makes the genuine record verifiable. Each publication is signed. So a reader sees that this record was issued by you, and every earlier version stays retrievable. Authentication becomes a check against a record you keep. That is what an auction house or a resale platform needs. Anyone verifies the signature with the Transpareo Time Machine.
What does the ban on destroying unsold goods mean for us?
Since 19 July 2026 large companies may no longer destroy unsold apparel, clothing accessories and footwear. Medium-sized companies follow on 19 July 2030, and micro and small companies are exempt. On top comes the duty to disclose the number and weight of unsold goods discarded, every year. Some houses have protected their price positioning by destroying stock. For them this is the most important rule on this page. It needs a data trail long before it needs a passport.
What about leather and the deforestation regulation?
Since 18 September 2026 cattle leather no longer falls under the Deforestation Regulation. A delegated regulation deleted raw, tanned and further-prepared cattle hides and leather from its list. Wooden jewellery caskets stay covered. The question of where the hide came from remains. Customers and retailers ask it, and the answer comes from your tannery contracts. In Transpareo the leather component keeps its origin and its evidence.
Can the passport carry the owner's name?
Customer data may go into the passport only with explicit consent. So think carefully before the passport carries a name. In Transpareo visibility is a property of every data field. A service history can be public while the owner-facing part stays behind logged access. You record a change of owner as an event that does not appear publicly. Personal fields can be erased, and the rest of the passport still verifies. The safest pattern keeps the object’s history in the passport and the person in your client system. More on the mechanics in disclosure does not cost you the signature.
How long does a passport have to stay reachable?
No act sets a period for these categories yet. Once one does, the passport stays available even after an insolvency. The object outlives the question anyway. A watch changes hands three times in forty years. If the passport is gone at the second sale, it is worthless. So what matters is what your provider does after a cancellation. With Transpareo, published passports stay reachable at a permanent address. Once registered in the EU registry, they go into a ten-year archive. Our provider checklist names more questions worth asking any provider.
Official documents
Legal sources for luxury goods to read for yourself: what each document is and when you need it.
- Regulation (EU) 2024/1781 (ESPR)The framework regulation for the product passport in every industry that gets one. It bans destroying unsold apparel, clothing accessories and footwear, requires disclosure of discarded stock and sets up the registry. Read the destruction ban first if you hold seasonal stock.
- Ecodesign and Energy Labelling Working Plan 2025-2030The Commission communication of 16 April 2025 with the first product groups and their indicative years. This is where you check whether your category is in the queue. It also sets out footwear’s separate study.
- Regulation (EU) 2017/821 on conflict mineralsThe supply-chain due diligence rules for Union importers of tin, tantalum, tungsten and gold. Its volume thresholds decide whether you are in scope. The duties have applied since 1 January 2021.
- Commission page on the Conflict Minerals RegulationThe Commission’s own overview, with the list of due diligence schemes recognised as equivalent. Worth a look before you build a scheme of your own.
- Implementing Regulation (EU) 2026/1778 on the DPP registryHow the central registry works, with identity verification, registration at model, batch or item level, versioning and retention. In this industry the item level is what counts.
- Delegated Regulation (EU) 2026/2102Recasts the list of covered products of the Deforestation Regulation, in force since 18 September 2026. Raw, tanned and further-prepared cattle hides and leather drop out. Wooden jewellery caskets stay covered.
- Commission page on the Deforestation RegulationThe current state of the EUDR with guidance and FAQ. Product scope and dates have moved more than once. Read the page itself before you plan around leather and wood.
- DPP page of the European CommissionThe official roadmap for the product passport with the state of the registry and the delegated acts. A new date for textiles or footwear appears here first.
Further reading on our blog
Transpareo signs each field of a product passport on its own, so a disclosed protected field keeps its proof. Its reader need not trust the platform.
Trust in a product passport rests on the signed record of the product itself. Transpareo Proofchain keeps it verifiable that way for ten years, longer than a platform usually lasts.
How companies use the compliance passport for lead generation, without greenwashing. Every QR scan is a consumer interaction.
How fashion brands close their data gaps at the weaver and the spinner. The ESPR duties for textiles are expected from 2029.
Give every object its record
Start free and issue signed, item-level passports that authenticate in a scan and keep their value at resale.